We have a subcontract with a VA Research
and Education Foundation. In performing our subrecipient monitoring duties
we find that the foundation does not have an A-133 audit conducted because they
claim not to have sufficient federal funds to require one.
Upon examination of their audited (not
A-133)financial statements we found that they did have more than $500K in
federal revenue from Interagency Personnel Agreements (IPAs). We asked
them why they did not have an A-133 audit and they said that, per Tony Ryan at
OPM, The Office of Personnel Management has determined that an IPA assignment is
not a federal award or a contract and therefore, reimbursements associated with
IPA assignments do not trigger the need for an A-133 audit.
If these agreements are issued under CFDA
27.011 Intergovernmental Personnel Act (IPA)
Mobility Program, wouldn't they be subject to A-133?
Is there another federal IPA program that
is not under a CFDA?
Has anyone else dealt with
this?
Thank you for any assistance you can
provide.
Ted
Ted Mordhorst
Assistant Director for
Compliance
Research Accounting & Analysis
Box 351122
3917
University Way NE
Seattle, WA 98105-6692
206-616-8678
Fax
206-543-0764
xxxxxx@u.washington.edu